Guide
EPA Section 608 records, and what software has to do
Updated
Section 608 compliance fails on paperwork far more often than on engineering. The duties are specific, they attach to an appliance rather than to a customer, and they need a technician in a plant room to capture the right fields the first time.
Talk to a specialist Five US HVAC platforms set against the EPA Section 608 duties, what each publishes, and the questions no vendor has answered in public.
The duties, precisely
The leak repair rules apply to appliances with a full charge of 50 or more pounds. The trigger rate then differs by equipment type: 10% for comfort cooling, 20% for commercial refrigeration and 30% for industrial process refrigeration, each measured over a 12 month period.
Once a leak is discovered, it must be repaired within 30 days, or a retrofit or retirement plan developed within 30 days and completed within a year, with a copy of that plan kept on site. Where the trigger rate is exceeded, initial and follow-up verification tests are required at the conclusion of repair efforts.
The EPA points to 40 CFR Part 82 Subpart F for the detailed recordkeeping provisions, and that is where to look rather than at any vendor's summary, including this one.
Why this is an asset problem, not a job problem
Every threshold above is per appliance and over a rolling twelve months. A system that records refrigerant added against a JOB can tell you what you used last Tuesday. It cannot tell you whether unit three at a site has crossed 10% in the last year, which is the question the regulation actually asks.
So the first thing to test in any demo is whether an appliance exists as a record in its own right, with a full charge on it, and whether refrigerant added and recovered attach to that record with dates.
The 30 day clock has to start itself
A deadline that depends on somebody remembering to raise a follow-up is not a control. What you want is a discovery date that opens a task automatically and a job that cannot be closed as complete without a repair record attached.
Then the verification requirement needs two linked visits recorded against one leak event. Most systems will happily record them as two unrelated jobs, which is exactly the shape that reads as compliant internally and proves nothing externally.
What none of the five vendors publishes
Refrigerant leak-rate tracking, by name, on any of the pages we read. That is worth knowing before a demo, because it means you are asking whether something can be configured rather than whether a feature exists.
Ask for the rolling twelve month leak rate for one appliance, produced live in the demo from data entered during the demo. A vendor that can do it will show you. A vendor that describes how it could be done with custom fields has answered the question.